Recently, the Centers for Medicare and Medicaid Services (CMS) released a report that provides insight into clinicians’ performance in the Quality Payment Program (QPP) in 2022. The QPP has two tracks, the Merit-based Incentive Payment System (MIPS) or the Advanced Alternative Payment Model (Advanced APM). Irrespective of which track a clinician participates in, a clinician’s performance in 2022 impacts their Medicare reimbursement they will receive this calendar year, 2024.
Importantly, clinicians were required to participate in MIPS for the 2022 performance year if they were: (1) a MIPS eligible clinician type; (2) enrolled as a Medicare provider before January 1, 2022; (3) exceeded the low-volume threshold, and (4) weren’t otherwise excluded (for example, by achieving QP status). There was an 11% drop in the number of MIPS eligible clinicians from 2021 to 2022, likely due to an increase in physicians achieving qualifying APM participant (QP) status
Data from the Report
The report outlines data and insights in four separate sections: (1) MIPS eligibility and participation, which reviews the participation and engagement of MIPS eligible clinicians; (2) MIPS performance, which reviews performance in the quality, cost, improvement activities, and promoting interoperability performance categories; (3) 2022 MIPS final scores and associated 2024 payment adjustments, which outlines the MIPS eligible clinicians’ final scores and payment adjustments; and (4) Advanced APM participation, which reviewed the volume of eligible clinicians who received QP status.
The data showed that MIPS eligible providers who actively participate are the ones that are successful in the program, with mean and median final scores above the 75-point performance threshold. The performance of clinicians who engage and those who do not are starkly different, with small practices that engage achieving a mean final score of 84.8 and a mean payment adjustment of 2.73% while small practices that did not submit data had a mean final score of 38.34 and a mean payment adjustment of -4.6%.
The 2022 performance year was the first year during which clinicians who performed well under their track received a sizable bonus. A perfect score in prior years resulted in a 1 to 2% bonus, but A perfect score in 2022 resulted in a greater than 8% payment bump for 2024 payments. While this discrepancy baffled interested parties for a while, the release of this report shows some insight into the reasoning behind the large payment bump.
The mean final score for all MIPS-eligible clinicians was 82.90 points and the median final score was 85.29 points, both lower than the 2021 scores. Additionally, since the performance thresholds increased from 60 points in 2021 to 75 points in 2022, those who passed the threshold received greater bonus amounts. The mean payment adjustment amount in 2022 was 2.6%, the median was 0.92%, and the maximum was 8.26%. CMS noted that the lower scores in 2022 were likely the result of the removal of quality measure bonus points, a change in the complex patient bonus methodology resulting in fewer clinicians being eligible for this bonus, the cost performance category being calculated for the first time since the 2019 performance year, and changes to performance category weights.
The report also notes that between 2021 and 2022, there was a 26% increase in Advanced APM participation and a 41% increase in the number of clinicians who achieved QP status.